Case Summary (G.R. No. 90019)
Summary of Prosecution's Case
The prosecution relied on testimonies from police officers who conducted a buy-bust operation after receiving reports about drug-pushing activities linked to a person known as "Willy" at 1941 Maria Orosa St., Malate, Manila. Prior to the arrest, a week-long surveillance confirmed that Fernandez was indeed selling drugs. On the day of the operation, armed with a marked P20-bill, police officers conducted the transaction, whereby Fernandez accepted the money and provided marijuana cigarettes in return. Following the transaction, Fernandez was apprehended, and the police found the marked money in his possession.
Key Evidence and Credibility Issues
The trial court's decision largely relied on the credibility of the police officers' testimonies. They were stationed nearby during the transaction, which provided them with visual confirmation of the sale, despite not hearing the conversations directly. The accused contested the credibility of these witnesses, asserting that the absence of testimony from the poseur-buyer and the informant weakened the prosecution's case. However, the court noted that the police officers' observations were substantial enough to support the guilty verdict.
Arguments from the Accused
In his appeal, Fernandez argued that the trial court erred by convicting him based solely on the testimonies of officers who did not witness the negotiation directly. He claimed that the inconsistencies in the testimonies of the officers created reasonable doubt regarding his guilt. Moreover, he contended that he was unjustly arrested after being falsely accused, stating that police demanded payment for his release and denied the charges against him.
Court's Analysis and Reasoning
The appellate court recognized that while the police officers had not overheard the actual negotiation, their visual confirmation of the transaction was critical in establishing Fernandez's guilt. The court dismissed the alleged inconsistencies as trivial and affirmed that the prosecution's evidence was substantial enough to prove Fer
...continue readingCase Syllabus (G.R. No. 90019)
Case Overview
- Case Citation: 298-A Phil. 265
- Court: First Division
- G.R. No.: 90019
- Date: December 08, 1993
- Parties: People of the Philippines (Plaintiff-Appellee) vs. Wilfredo Fernandez y Bisco (Accused-Appellant)
Background of the Case
- Wilfredo Fernandez y Bisco was charged with violating Section 4 of R.A. No. 6425, known as the Dangerous Drugs Act of 1972.
- The alleged crime involved selling five hand-rolled marijuana cigarettes to an undercover police officer on February 10, 1987, for P20.00.
- Following a trial, the Regional Trial Court of Manila found the accused guilty and sentenced him to life imprisonment along with a fine of P20,000.00.
Issues Raised on Appeal
- The accused appealed the conviction, asserting several grounds for his appeal:
- Lack of Direct Witness Testimony: The trial court relied on witnesses who were not present during the sale, specifically omitting the testimonies of the poseur-buyer and the informant.
- Credibility of Evidence: The appellant contended that the prosecution's evidence was inherently incredible and that the trial court failed to consider exculpatory evidence presented by the defense.
Key Facts of the Case
- Prior to the incident, the Narcotics Control and Investigation Service of the Western Police District (NCIS-WPD) had received multiple reports regarding drug-pushing activities in the area attributed to an individual known as "Willy.&q